2023 Activity Report of the Commission for the Control of INTERPOL’s Files (CCF), an independent and impartial body within INTERPOL, highlights increasing workload and delays in processing requests and complaints.

What is CCF?

The CCF operates under its own Statute and INTERPOL’s Constitution, with seven independent members serving in their personal capacities. These members are organized into two chambers: the Supervisory and Advisory Chamber, which oversees compliance and provides recommendations, and the Requests Chamber, which processes individual requests for data access, correction, or deletion. Together, these chambers ensure that the CCF can effectively fulfill its supervisory, advisory, and decision-making mandates. The CCF’s core responsibility is to ensure that the processing of personal data for police purposes complies with INTERPOL’s rules and international standards, particularly those that protect fundamental human rights.

Increasing workload

The report highlights the substantial workload handled by the CCF in 2023, reflecting a marked increase in both volume and complexity over the past three years. The CCF received 2,793 requests, the highest number in its history, representing a 70% increase since 2021. These requests included 1,101 access requests, 1,021 complaints seeking the correction or deletion of data, and 557 applications for the revision of prior decisions.

Delays

Admissibility rates for access requests and complaints exceeded 90%. However, the influx of cases and their growing complexity created processing delays. Although 70% of access requests were resolved within the four-month statutory timeframe and 85% of complaints within nine-month statutory timeframe, significant delays occurred in some cases. Thirty percent of access requests took an average of seven to eight months to complete, and 15% of complaints required 12 to 15 months for resolution. 

Outcomes of cases

The report also highlights the CCF’s decision-making outcomes in 2023. Of the 500 admissible complaints reviewed, 68% were found non-compliant with INTERPOL’s rules. Many of these cases involved politically sensitive issues or disputes over the validity of Red Notices or Diffusions, often requiring the CCF to weigh international legal standards and the principles of the Universal Declaration of Human Rights. In some instances, the lack of cooperation by NCBs resulted in data being deleted due to an inability to confirm their validity.

Beyond individual cases, the Supervisory and Advisory Chamber reviewed nine major projects, conducted three spot checks, and issued recommendations aimed at improving data protection standards. These efforts reflect the CCF’s broader role in ensuring systemic compliance with INTERPOL’s rules.

The 2023 Annual Activity Report underscores the CCF’s critical role in safeguarding the integrity of INTERPOL’s data processing activities while upholding human rights and international legal standards. Despite significant achievements, the report highlights persistent challenges, including delays in 15% of complaints, 30% of access requests, and non-cooperation by some NCBs, which hinder the CCF’s ability to fully protect the rights of individuals.

These challenges underscore the need for systemic reforms to strengthen accountability mechanisms for member states and to provide the CCF with additional resources to handle the increasing complexity and volume of requests. Without such reforms, the CCF’s capacity to balance global security needs with the protection of individual rights and freedoms may be compromised. This report serves as a reminder of the importance of continuous improvement to ensure that INTERPOL’s activities remain both effective and just.

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Ali Yildiz is a prominent Interpol lawyer and has a track record of success in obtaining the deletion of data requests submitted to Interpol’s CCF. If you need assistance with any Interpol matter, please contact us.